18/10/2010 - Smart Meters - DECC and Ofgem Consultation

Smart Meters - smart idea - not so smart implementation

Ofgem ask us to invest £175 now to save £14 a year by 2020

According to Ofgem's own figures, an average household will pay about half of the £350 cost per home to install the meters through energy bills over the next few years, yet will save only about £14 a year on annual gas and electricity bills (i.e. about 1% per year) by 2020. So, what exactly are the public getting from this initiative?

According to DECC and OFGEM, smart meters have the potential to deliver the following benefits to consumers:

• better information can help consumers cut energy use
• smart meters end the need for estimated bills and the need to be in when the meter reader calls
• consumers will benefit from more choice in tariffs, for example time of use tariffs offering cheaper electricity during the night when demand for energy is lower
• in due course switching will become quicker and easier – days rather than weeks - increasing the competitive pressure on energy suppliers
• make switching between payment methods easier, i.e. switching between credit and prepayment modes using the same meter
• smart meters will give much clearer information, allowing consumers to compare competing tariffs more easily
• smart meters could detect problems with a consumer's electricity supply
• smart meters will make it easier for suppliers and third parties to offer consumers tailored energy efficiency advice.

In a presentation by Ofgem in August 2010, Robert Hull, Commercial Managing Director of Ofgem E-Serve, claimed the following benefits of their proposed approach:

• Accelerate set-up while delivering majority of benefits
• Independence of procurement and management function from service providers from service providers
• Scope for effective competition
• Flexibility for development
• Certainty to all stakeholders
• Builds on existing industry models

Paraphrased, it seems the benefits are "people can change supplier or payment method more easily" and "people will know what they're using better". Most people who are trying to keep the usage low can already do so quite happily by simply keeping track of their used units over time and turning off things when possible; it is not clear what exactly the proposed smart meters will do other than convert this into financial information - this is hardly rocket science when we pay per unit anyway.

Note that, in these two lists, there is nothing serious listed about energy efficiency or time-variable tariffs (apart from cheaper electricity at night which we already have via Economy-7 etc) or about intelligent appliance control. These lists do not represent what true "Smart Meter" technology is really intended to be about. Instead, we have a publicly championed "green brownie points" idea that allows the industry to cut their costs at our expense.

In our opinion, Ofgem should have been on the list of quangos that are being abolished. They do not acknowledge individual enquiries from members of the public which they claim are not usually their direct concern as Regulator. They tried to completely undermine the Department of Health SAGE process by boycotting the idea of a stakeholder engagement on the issue. It would seem that Ofgem are seriously letting down electricity consumers regarding the implementation of Smart Meters and on not failing to properly regulate Quality of Supply which we believe is one of their duties.

Their announced plans save the electricity industry money by laying off thousands of meter readers and call-centre staff. On the other hand, the public get to pick up the tab of over £10bn by paying for the meter installations through our bills and also have to pay for the state benefits paid to our ex-meter readers who have no guarantee of new jobs. The actual meters will almost certainly be made in China (or elsewhere where the labour and parts can be sourced much more cheaply). We also get forced to have a radio-frequency base-station transmitter located inside our homes that many people believe will adversely affect their well-being.

Ofgem's current plans are that we should not be charged extra up-front costs for a 'basic' In-Home-Display (IHD), but that suppliers will be able to charge us for "enhanced information" - both for a more complex display unit and, on an on-going charge, for supplying extra information such as is also shown below. We suspect that will cost us more than the £14 that Ofgem predict the average consumer will be saving.

Real Smart metering

We do need to reduce the amount of energy we use, and use it more efficiently. The smart meter documents do specify a lot more features but, quite amazingly, there seem to be no DECC/Ofgem proposals to actually bring these into use within the next ten years. You can download our consultation response from the link at the end of this page. We extract and expand on some of the key issues below.

An example of useful Smart House display screens (by Dan Lockton)

If we are to implement Smart Metering we need to be far more proactive than what is set out in the above DECC/Ofgem lists. These are the sort of features that we should be aiming to have fully implemented on our in-house display by 2020:

UK Industry leads the way

Meanwhile, the electricity industry has been intelligently working away at determining the requirements of proper Smart Meters and how they can best be implemented. The Energy Retail Association SRSM Project seems to have been the leading light in investigating the issues around Smart Meters for the UK and has produced some excellent background documents. They include far more energy conservation management strategies than listed above by DECC or Ofgem, though the Wide Area Network (WAN) documents (web-links at bottom) were done partly for BERR, DECC's predecessor. They also have prepared and published a number of detailed examinations of the communications possibilities and comparisons - including wired options (though there is no mention of the needs of electrically hypersensitive people). Their reports are detailed and quite technical and clearly show that wireless is not essential - their assessments support Power Line Communications (PLC) for outside communications and M-Bus for inside the home (available as wired or wireless) as being valid and suitable options. However, they currently avoid suggesting PLC and are only promoting wireless networks as the best way forward.

Wireless is not necessary - just cheaper and easier to implement

Although the DECC prospectus states that they consulted 'stakeholders', other groups clearly still need to be consulted. The most significant issue which has not been adequately addressed is the proposed use of wireless communication for the smart meter. No UK groups who are concerned by reported problems of chronic RF exposure (e.g. ES-UK, Radiation Research Trust, Powerwatch, Mast Action, Mast Sanity, hese-uk, Cavisoc, Wifiinschools, Wiredchild, etc) have so far been directly consulted. Nor are any of these represented on the Ofgem Smart Metering Implementation Programme Consumer Advisory Group. There are significant public protests in the USA, Canada, New Zealand, Australia and the Netherlands against the installation of smart meters and many new users are also reporting EMC interference issues with existing electronic devices in their homes. DECC and GEMA have not yet fulfilled their legislated duties in this regard.

A significant number of consumers (we estimate between 2 and 10%) will not want a wireless communicating smart meter in their home. These people choose to minimise their exposure to wireless technology. There are significant protests in the USA, Canada, New Zealand, Australia and the Netherlands against the installation of smart meters and many new users are also reporting EMC interference issues with existing electronic devices in their homes.

Ofgem and DECC commissioned FDS International to canvas consumers' views on the smart meters. This did not include the issue of using wireless technology or RF radiation. The only reference to wireless technology is in respect to whether home display should be plug in or wireless. Given the concerns of many members of the public about wireless technology in the form of mobile phone masts in the UK and the objections to smart meters using wireless technology in other countries, this should have been properly addressed. It was not.

Wireless will not work from inside screened homes

Increasing numbers of people are reporting electrical sensitivity (ES or EHS) problems. Many of these people are choosing to screen their homes against RF signals from outside. Many electricity meters are well inside a house (often under the stairs). Wireless Smart Meter WAN networks will not connect to a meter located inside an RF screened home. So this needs to be addressed - maybe by offering to relocate the meters to the outside of a house when requested.

Our response highlighted issues regarding responsibilities under the Disability Discrimination Act 1995, the Equality Act 2010 which replaces it and extends the duties, and the Human Rights Act 1998. There are lots of details in our response (see download link, below). We claim that we have the right not be be forced to have RF transmitters inside our house.

What are MESH Networks?

The meters need to be communicated with by the electricity suppliers using the Wide Area Network (WAN). There are a number of technologies that may be considered to do this - these are well discussed in the industry documents (linked above). However, it is regarded by both government and industry as crucial that they cannot assume a phone-land-line connection, nor a broadband connection. So that only leaves PLC or Wireless for the WAN.

A wireless WAN can be by a variety of means, but the cheapest and most resilient against failure is a MESH network such as is being installed in the USA and Canada. This allows every electricity meter to "talk" to all nearby meters within about 100 metres and pass on messages and only requires one external Access Point (= base station) for every 1000 or so homes. This means that the meters in houses close to the Access Points will be passing on messages for hundreds of other meters 24-7. So they are proposing to use their equipment inside your house to transmit and receive other people's data using microwaves.

Low-bandwidth (up to 28k8 bps) Power Line Communications (PLC) uses low frequency RF signals to communicate between equipment in the local electricity substation and your meter using the electricity supply cables. It is cheap, reliable and more secure that wireless. It does put small amounts of LF RF onto the wires, but this can easily be filtered inside the Smart Meter so that it does not come on to your home wiring. The only downside is that the communications equipment will have to be located at each local substation (it could be in an external cabinet) and it will be difficult for many different companies to openly compete to supply and maintain it. As the Government is proposing a central Data Collection Agency (in order to protect privacy) they can co-ordinate the PLC provider(s) and we do not see 'competition' as a valid objection to using PLC.

PLC networks are already well proven in practice.

The Home Area Network (HAN) inside your home

Here all the current proposals are for wireless networks - though one, the wireless M-Bus was actually designed as a simple wired network especially for Smart Meters and is already used as a wired home network in some European countries, including Germany. This would be an ideal choice as the meters could be supplied with an alternative wired M-Bus port and with a way of disabling the wireless function. Then we could easily choose to have a single screened wire connection in our homes instead of wireless.

Unlike some other countries, the UK forbid any directly wired connections to a gas meter. This would require either a opto-isolated coupling at the outside of the gas meter enclosure (as is required for industrial intrinsically safe installations) or a short length of fibre-optic cable as the final connection to connect from a point near to the gas meter into the enclosure and meter. Nowadays, that is not difficult or expensive.

M-Bus networks are already well proven in practice.

Security of supply

Powerwatch has significant concerns about the security of electricity supplies in times of war or against a serious terrorist attack. The UK Government has just announced that Tier One threats include cyber and other terrorism. Wireless meters are much more vulnerable to cyber-attack (hacking) and to electromagnetic pulse damage.

Wireless systems are almost impossible to protect against an electromagnetic pulse attack and civilian systems are not protected. Source Region Electro-magnetic Pulse (SREMP) is produced by a low-altitude nuclear burst such as would come from a air-burst EMP cruise missile. A single such pulse could cause most electronics in a 30 km area to permanently fail. The electricity supplies for wide areas of the UK could be disabled with ease. There have been many wars in the last 100 years and terrorism is increasing.

The old electromechanical rotating-disk meters would not be damaged. The industry has already been allowed to install simple electronic meters - are they EMP protected in any way? Probably not. Changing them to wireless meters will make them far more vulnerable. Meters must be designed to fail in a "supply on" mode. This issue was not addressed in the DECC/Ofgem specification documents and must be properly addressed in the design process.

In conclusion

Smart Metering will be brought in. Variable tariffs will be used, especially for electricity, to discourage unecessary use during times of high load. This will significantly reduce the need to build extra power stations, reduce the associated CO2 emissions and lower the total costs of providing the UK with an adequate electricity supply.

No UK groups who are concerned about reported problems of chronic RF exposure (see above) have so far been directly consulted, nor are any of them represented on the Ofgem Smart Metering Implementation Programme Consumer Advisory Group.

A 2005 report [1] by the UK Health Protection Agency concluded that electromagnetic hypersensitivity syndrome needs to be considered in ways other than its aetiology; that is, the suffering is real, even if the underlying cause may not be thought to be related to actual exposure to electromagnetic fields. In Sweden electromagnetic hypersensitivity is an officially recognized functional impairment, but it is not regarded as a disease.[2] However, people with functional impairments have the right for their needs to be considered when a government changes the ways things are done in society, especially in their own homes.

The Equality Act 2010 requires provision to be made to support people with a functional impairment.
Regulations may make provision for a condition of a prescribed description to be, or not to be, an impairment.
The effect of an impairment is to be considered long-term if:

• it has lasted for at least 12 months; or
• it is likely to last for at least 12 months; or
• it is likely to last for the rest of the life of the person affected;
• if an impairment ceases to have a substantial adverse effect on a person's ability to carry out normal day-to-day activities, it is to be treated as continuing to have that effect if that effect is likely to recur

DECC policy should not unnecessarily decrease the well-being and health of people who suffer from EHS syndrome by insisting on the multiple use of RF technology when viable, cost effective, alternatives exist.

The Electricity Act 1989 (with amendments to 2010) states:

• "For the purposes of this section an electricity safety issue is anything concerning the supply of electricity which may affect the health and safety of members of the public;"
• In performing that duty, the Secretary of State or the Authority shall have regard to the interests of individuals who are disabled or chronically sick;
• The DECC Fact Sheet regarding the Energy Act 2010 (energybillfactsheet3.pdf) states: "Whilst promotion of competition is the foundation of consumer protection, Ofgem should consider whether there are alternative or additional measures that might better protect consumer interests before taking action."
• The DECC Fact Sheet also states that this means: "Ensure that the interests of all consumers, future and present, are appropriately taken into account when decisions are made in relation to the gas and electricity markets."

Powerwatch strongly believes that it would be quite wrong, and may be illegal, to force everyone to have a wireless-networks-based Smart Meter in their home when there are viable and proven alternatives. Low-bandwidth Power Line Communications can supply a completely adequate, reliable and secure Wide Area Network service and the M-Bus is one option which offers either wired or wireless connections within the home.

References

1. Irvine, N. (2005) Definition, epidemiology and management of electrical sensitivity. UK Health Protection Agency, HPA-RPD-010
2. Johansson O (2006). Electrohypersensitivity: state-of-the-art of a functional impairment. Electromagn Biol Med 25 (4): 245–58

Links

There are many pages and sites on the Internet discussing Smart Meters. We have restricted our link here to what we regard as the most pertinent to the UK debate. Various Acts such as the Equality Act 2010 also need to be consulted.

(66 KB) Powerwatch consultation response (you will need to read the DECC Questions to make sense of some of our responses)

DECC Consultation documents to download

Ofgem's Smart Metering home page with links to downloads

This page has links to content that requires a .pdf reader such as Adobe Acrobat Reader